- 3 - FINDINGS OF FACT We incorporate herein the findings of fact set forth in Riggs Natl. Corp. & Subs. v. Commissioner, 107 T.C. 301 (1996) (Riggs I), revd. and remanded 163 F.3d 1363 (D.C. Cir. 1999) (Riggs II), and Riggs III by this reference. We also incorporate herein the stipulations and exhibits in Riggs I and Riggs III by this reference. For ease of understanding, we repeat those facts set forth in Riggs I and Riggs III which we deem necessary to clarify the supplemental findings set forth herein and the ensuing opinion involving the issue for decision. In Brazil, the Central Bank performed a number of governmental functions in conjunction with Banco do Brazil, including the unified management and operation of Brazil’s monetary and financial system under what was known as the caixa unico system.3 From 1965 through 1986, Banco do Brazil had four primary functions: (1) A commercial bank, (2) a monetary authority, (3) management control and distribution of currency, and (4) responsibility for bank clearing. Further, like the Central Bank, Banco do Brazil functioned as: (1) A lender of last resort to public-sector entities, (2) a development bank responsible for various subsidized credit programs of the Brazilian Government, and (3) a fiscal authority that managed the 3Until the Central Bank was formed in 1965, Banco do Brazil served as the country’s sole monetary authority.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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